Despite impressive progress in perinatology, fetal injuries from arrest of the shoulders at birth have not decreased in recent decades. Based upon sporadic reports of Erb's palsy in neonates born by Cesarean section, some obstetricians embraced the theory recently that brachial plexus lesions often derive from spontaneous forces acting in utero. Having reviewed three hundred malpractice claims involving fetal injuries attributed to shoulder dystocia at birth, the authors found only two cases connected with abdominal deliveries. One followed manual replacement of the already delivered fetal head into the pelvis after sequential vacuum and forceps procedures and failed manual extraction of the body. The other was an elective repeat Cesarean section where extensive adhesions limited the available space for the lower segment transverse uterine incision. Coincidental fracture of the clavicle and absence of contractures or deformities indicated that the brachial plexus injury was acute, having resulted from forceful traction at delivery.